Being an international company, we make a great emphasis on our own Corporate Ethics Code and legal compliance. Saying this, we mean that it is not just the strict adherence to legislation and rules, but also the inclination of our commercial operations towards such principles as decency, safety, transparency, and perfection.

Therefore, the Corporate Ethics Code contains the mandatory formulations of the key values and major principles of the conduct for the ALPHA Company, and it applies to all of the company’s employees and suppliers. Even the infringement of rights of a single member of staff can cause an irreversible reputational damage. Along with the said code, the ALPHA Company sets not only the fundamental principles for its employees, since we also guarantee to our partners that we will comply with and respect the legislation and norms worldwide. We expect the same from our business partners. Our relationships with all the partners must be based on objective criteria particularly on the quality, reliability, as well as adherence to environmental and social standards. The Corporate Ethics Code was for the first time enacted in 2010, it was revised in 2012 and 2015, and now it contains the following clauses:

§1 Legal Compliance

The laws of each applicable jurisdiction shall be respected and complied with.

§2 Corruption

In most countries globally the anti-bribery laws prohibit bribery of both the national and foreign public officials, as well as of employees of domestic and foreign companies. All our staff members are expected to act in Company’s best interest and to preserve its good reputation. These include the fight against corruption of any kind. We never tolerate any form of corruption or bribery and we also reject any illegal offers of money or similar benefits in order to influence any decision-making. The same applies to our business partners, who also shall be governed by this Ethics Code entirely.

§3 Data Protection

Also the intangible assets, such as knowledge, intelligent property rights and proprietary data belong to the property of our customers or to ALPHA. While processing the data of our employees or business partners we adhere to strict standards. All the data collected or saved by ALPHA is processed exclusively for a specific purpose, carefully and in a comprehensible manner, as well as in accordance with the applicable data protection laws.

§4 Personal Rights

Not only the major rights of all employees shall be respected. Besides, our company promotes the creation of equal opportunities and formation of equal attitudes to our employees regardless of their color of skin, race, ethnicity, social setup, any kind of handicap, sexual preferences, and political or religious views, and also regardless of their gender and age. Nobody shall hire a person against his or her own will and nobody shall force a person to work. Furthermore, we never tolerate inadequate treatment of the operating personnel, for instance, in the form of psychological pressure, sexual or personal harassment or discrimination. The maximum working time of an employee as specified by the law in any country and minimum legally acceptable age for employment must be respected on a constant basis.

§5 Health and Safety of Employees

We assume the responsibility for the health and safety of our employees, and we therefore minimize the risks and guarantee the optimal safety precautions against accidents and occupational diseases.

§6 Environmental Protection

Both our company itself and our suppliers assume the obligation to comply with the legal norms and international standards for continuous protection of the environment, and also to cut down the environmental pollution, and to continuously improve the environment protection at the same time.

§7 Supply System

Furthermore, we assume the obligation not only to duly promote the compliance with the contents of this Corporate Ethics Code on the part of our suppliers, but also to proceed in accordance with the antidiscrimination principles in selecting the suppliers and in our contacts with them. In turn, our suppliers should facilitate the compliance with this Corporate Ethics Code on the part of our subcontractors and should not cooperate with the companies violating this Corporate Ethics Code.

Quoted as of January 07th, 2018